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Roberts v. Galen of Virginia, Inc., 525 U.S. 249 (1999)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Roberts v. Galen of Virginia, Inc., 525 U.S. 249 (1999)
No. 97-53 Roberts v. Galen of Virginia, Inc. Decided January 13, 1999 525 U.S. 249
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
Syllabus
The Emergency Medical Treatment and Active Labor Act (EMTALA) places screening and stabilization obligations upon hospitals and emergency rooms that receive patients suffering from an emergency medical condition. Among other things, the statute requires a hospital with an emergency department to provide "an appropriate medical screening examination" for an emergency room patient, 42 U.S.C. § 1395dd(a); requires the hospital to provide either medical examination and treatment to stabilize the patient or for transfer to another medical facility, § 1395dd(b), and authorizes civil fines and a private cause of action for violations of the statute, § 1395dd(d). A severely injured Wanda Johnson was rushed to respondent’s hospital and remained there, in a volatile state of health, for about six weeks. She was then transferred to another facility, where her condition deteriorated significantly. Petitioner Roberts, her guardian, filed a § 1395dd(d) action, alleging § 1395dd(b) violations. The District Court granted respondent summary judgment on the grounds that petitioner had failed to show that either the medical that Johnson was stable or the decision to transfer her was caused by an improper motive. The Sixth Circuit affirmed, holding that § 1395dd(b) requires proof of an improper motive.
Held: Section 1395dd(b) does not require proof that a hospital acted with an improper motive in failing to stabilize a patient. The Sixth Circuit’s holding extended earlier Circuit precedent deciding that § 1395dd(a)’s "appropriate medical screening" duty also required proof of an improper motive. See Cleland v. Bronson Health Care Group, Inc., 917 F.2d 266. There, the court was concerned that the term "appropriate" might be interpreted incorrectly to permit federal liability under EMTALA for any violation covered by state malpractice law. Id. at 271. However, § 1395dd(b)’s text contains no appropriateness requirement, nor can it reasonably be read to require an improper motive. The Court declines to address, at this stage of the litigation, respondent’s two alternative grounds for affirming the decision below.
111 F.3d 405 reversed and remanded.
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Chicago: U.S. Supreme Court, "Syllabus," Roberts v. Galen of Virginia, Inc., 525 U.S. 249 (1999) in 525 U.S. 249 525 U.S. 250. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=3HJ7TNYTZXF4UNT.
MLA: U.S. Supreme Court. "Syllabus." Roberts v. Galen of Virginia, Inc., 525 U.S. 249 (1999), in 525 U.S. 249, page 525 U.S. 250. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=3HJ7TNYTZXF4UNT.
Harvard: U.S. Supreme Court, 'Syllabus' in Roberts v. Galen of Virginia, Inc., 525 U.S. 249 (1999). cited in 1999, 525 U.S. 249, pp.525 U.S. 250. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=3HJ7TNYTZXF4UNT.
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